November 1, 2021

The Honorable Pete Buttigieg 

U.S. Secretary of Transportation 

1200 New Jersey Ave, SE 

Washington, DC 20590

Dear Secretary Buttigieg: 

The Metrics and Minimum Standards for Intercity Passenger Rail Service final rule set forth at 49 C.F.R. 

Part 273 and published by the Federal Railroad Administration (“FRA”) on November 16, 2020 (the 

“Final Rule”), introduces a certified schedule metric that requires Amtrak to report to the FRA the 

number of certified Amtrak schedules, uncertified schedules, and disputed schedules, by train, route, and 

host railroad.

The Final Rule defines a “certified schedule” as a published Amtrak train schedule that Amtrak and the 

host railroad jointly certify is aligned with the customer on-time performance (“OTP”) metric and 

standard set forth in the Final Rule. The customer OTP metric is the percentage of all customers who 

arrive at their detraining point no later than fifteen (15) minutes after their published scheduled arrival 

time, reported by train and by route, and the customer OTP standard is eighty (80) percent for any two

consecutive calendar quarters. See 49 C.F.R. 273.5(a)(1) & (2). 

As required by the Final Rule, Amtrak and Metro-North Commuter Railroad Company (MNRR) are 

transmitting this joint letter reporting the following schedules that remain uncertified as of October 31, 

2021, as agreement has not been reached on whether the schedules are aligned with the customer OTP 

metric and standard:

1. Acela Trains 2150, 2151, 2154, 2155, 2159, 2160, 2163, 2164, 2165, 2167, 2168, 2171, 2175, 

2190, 2253, 2254, 2255, 2256, 2258, 2259, 2260, 2261, 2275 and 2290 

2. Adirondack Trains 68 and 69 

3. Ethan Allen Express Trains 290, 291, 292, 293, 295 and 296 

4. Maple Leaf Trains 63 and 64

5. New York – Albany Trains 230, 232, 233, 234, 235, 236, 237, 238, 241, 242, 243, 244, 245, 250, 

252, 253, 254, 255, 256, 259, 260 and 261 

6. New York – Niagara Falls Trains 280, 281, 283, 284 and 288 

7. Northeast Regional Trains 132, 137, 140, 141, 146, 148, 149, 150, 163, 167, 168, 177, 178, and 

179 

8. Richmond/Newport News/Norfolk Trains 65, 66, 67, 82, 86, 95, 96, 174 and 194 

AMTRAK

1 Massachusetts Avenue, NW, Washington, DC 20001

Email william.flynn@amtrak.com Tel 202-906-3963 

William J. Flynn

Chief Executive Officer
The Honorable Pete Buttigieg

November 1, 2021

Page 2

9. Roanoke Trains 171 and 176 

10. Vermonter Trains 54, 55, 56 and 57. 

Exhibit A details Amtrak’s position regarding the components of the train schedules upon which Amtrak 

and MNRR have not yet agreed, signed by me. 

Exhibit B details MNRR’s position regarding the components of the train schedules upon which Amtrak 

and MNRR have not yet agreed, signed by MNRR President Catherine Rinaldi. 

Amtrak and MNRR will continue to meet regularly to discuss the certification of all schedules. Please let 

us know if you have any questions regarding the information provided in this transmittal.

Sincerely,

William J. Flynn

Chief Executive Officer

Attachments

cc: The Honorable Martin J. Oberman, Chairman, Surface Transportation Board 

 The Honorable Peter A. DeFazio, Chair, Committee on Transportation and Infrastructure, U.S. 

House of Representatives

 The Honorable Sam Graves, Ranking Member, Committee on Transportation and Infrastructure, 

U.S. House of Representatives 

 The Honorable Maria Cantwell, Chair, Committee on Commerce, Science, and Transportation, 

U.S. Senate 

 The Honorable Roger Wicker, Ranking Member, Committee on Commerce, Science, and 

Transportation, U.S. Senate 

 The Honorable Rosa L. DeLauro, Chair, Committee on Appropriations, U.S. House of 

Representatives

 The Honorable Kay Granger, Ranking Member, Committee on Appropriations, U.S. House of 

Representatives

 The Honorable Patrick Leahy, Chair, Committee on Appropriations, U.S. Senate 

 The Honorable Richard Shelby, Ranking Member, Committee on Appropriations, U.S. Senate 

 The Honorable Don Beyer, U.S. House of Representatives 
The Honorable Pete Buttigieg

November 1, 2021

Page 3 

 The Honorable Richard Blumenthal, U.S. Senate 

 The Honorable Cory Booker, U.S. Senate 

The Honorable Jamaal Bowman, U.S. House of Representatives

 The Honorable Brendan Boyle, U.S. House of Representatives 

 The Honorable Anthony Brown, U.S. House of Representatives 

 The Honorable Ben Cardin, U.S. Senate 

 The Honorable Tom Carper, U.S. Senate 

 The Honorable Bob Casey, U.S. Senate 

 The Honorable David Cicilline, U.S. House of Representatives 

 The Honorable Yvette Clark, U.S. House of Representatives 

 The Honorable Ben Cline, U.S. House of Representatives 

 The Honorable Gerry Connolly, U.S. House of Representatives 

 The Honorable Chris Coons, U.S. Senate 

 The Honorable Joe Courtney, U.S. House of Representatives 

 The Honorable Madeleine Dean, U.S. House of Representatives

 The Honorable Antonio Delgado, U.S. House of Representatives 

 The Honorable Adriano Espaillat, U.S. House of Representatives 

 The Honorable Dwight Evans, U.S. House of Representatives 

 The Honorable Brian Fitzpatrick, U.S. House of Representatives 

 The Honorable Kirsten Gillibrand, U.S. Senate 

 The Honorable Bob Good, U.S. House of Representatives 

 The Honorable Morgan Griffith, U.S. House of Representatives 

 The Honorable Andy Harris, U.S. House of Representatives 

 The Honorable Maggie Hassan, U.S. Senate 

 The Honorable Jahana Hayes, U.S. House of Representatives 

 The Honorable Brian Higgins, U.S. House of Representatives 

 The Honorable Jim Himes, U.S. House of Representatives 

 The Honorable Steny Hoyer, U.S. House of Representatives 

The Honorable Chris Jacobs, U.S. House of Representatives

The Honorable Hakeem Jeffries, U.S. House of Representatives

 The Honorable Mondaire Jones, U.S. House of Representatives 

 The Honorable Tim Kaine, U.S. Senate 

 The Honorable John Katko, U.S. House of Representatives

 The Honorable Ann McLane Kuster, U.S. House of Representatives 

 The Honorable Jim Langevin, U.S. House of Representatives 

 The Honorable John Larson, U.S. House of Representatives 

 The Honorable Elaine Luria, U.S. House of Representatives

 The Honorable Stephen Lynch, U.S. House of Representatives 

 The Honorable Nicole Malliotakis, U.S. House of Representatives 

 The Honorable Carolyn Maloney, U.S. House of Representatives 

 The Honorable Sean Patrick Maloney, U.S. House of Representatives

 
The Honorable Pete Buttigieg

November 1, 2021

Page 4 

 The Honorable Ed Markey, U.S. Senate 

 The Honorable Donald McEachin, U.S. House of Representatives 

 The Honorable James McGovern, U.S. House of Representatives 

 The Honorable Gregory W. Meeks, U.S. House of Representatives

 The Honorable Bob Menendez, U.S. Senate 

 The Honorable Grace Meng, U.S. House of Representatives 

The Honorable Kweisi Mfume, U.S. House of Representatives

 The Honorable Joseph Morelle, U.S. House of Representatives

 The Honorable Chris Murphy, U.S. Senate 

 The Honorable Jerrold Nadler, U.S. House of Representatives 

 The Honorable Richard Neal, U.S. House of Representatives 

 The Honorable Donald Norcross, U.S. House of Representatives 

 The Honorable Eleanor Holmes Norton, U.S. House of Representatives 

 The Honorable Alexandria Ocasio-Cortez, U.S. House of Representatives 

 The Honorable Frank Pallone, Jr., U.S. House of Representatives 

 The Honorable Donald M. Payne, Jr., U.S. House of Representatives 

 The Honorable Ayanna Pressley, U.S. House of Representatives 

 The Honorable Jamie Raskin, U.S. House of Representatives 

 The Honorable Jack Reed, U.S. Senate 

 The Honorable Kathleen Rice, U.S. House of Representatives 

 The Honorable Lisa Blunt Rochester, U.S. House of Representatives 

 The Honorable C. A. Dutch Ruppersberger, U.S. House of Representatives 

 The Honorable Bernie Sanders, U.S. Senate 

 The Honorable John P. Sarbanes, U.S. House of Representatives 

 The Honorable Mary Gay Scanlon, U.S. House of Representatives

 The Honorable Chuck Schumer, U.S. Senate 

 The Honorable Bobby Scott, U.S. House of Representatives 

 The Honorable Jeanne Shaheen, U.S. Senate 

 The Honorable Albio Sires, U.S. House of Representatives 

 The Honorable Christopher H. Smith, U.S. House of Representatives

 The Honorable Abigail Spanberger, U.S. House of Representatives 

 The Honorable Elise Stefanik, U.S. House of Representatives 

 The Honorable Thomas Suozzi, U.S. House of Representatives 

 The Honorable Claudia Tenney, U.S. House of Representatives

 The Honorable Paul Tonko, U.S. House of Representatives 

 The Honorable Pat Toomey, U.S. Senate 

The Honorable Ritchie Torres, U.S. House of Representatives

 The Honorable Chris Van Hollen, U.S. Senate 

 The Honorable Nydia Velazquez, U.S. House of Representatives

 The Honorable Mark Warner, U.S. Senate 

 The Honorable Elizabeth Warren, U.S. Senate 

 
The Honorable Pete Buttigieg

November 1, 2021

Page 5 

 

 The Honorable Bonnie Watson Coleman, U.S. House of Representatives 

The Honorable Peter Welch, U.S. House of Representatives 

 The Honorable Jennifer Wexton, U.S. House of Representatives 

 The Honorable Sheldon Whitehouse, U.S. Senate 

 The Honorable Rob Wittman, U.S. House of Representatives 
Page 1 of 6 

Exhibit A

Amtrak’s position regarding the disagreed upon components of the train schedules.

The Final Rule defines a “certified schedule” as a published train schedule that Amtrak and the host railroad 

jointly certify is aligned with the customer on-time performance (“OTP”) metric and minimum standard set 

forth in the Final Rule. To date, MNRR and Amtrak have been unable to reach agreement to certify 70% 

(90 uncertified of 129 total) of the Amtrak train schedules operating on MNRR. 

Amtrak has worked with over 20 host railroads to successfully certify nearly 90% of train schedules to date. 

While Amtrak has invested, and will continue to invest, significant management time and is engaged at all 

levels to work towards resolution, MNRR remains the only host railroad for which Amtrak has uncertified 

schedules. 

As we are approaching the one-year anniversary of the publication of FRA’s Final Rule, we do not 

currently see a pathway to certification with MNRR for the remaining 90 train schedules. 

Sincerely,

William J. Flynn

Chief Executive Officer

Amtrak
Page 2 of 6 

Table 1: Amtrak Schedule Alignment Analysis Results by Train

Service Train

Train OriginDestination 

1. Prior Customer 

OTP Schedule 

Modifications

2. Strong Historical 

Performance 

3. Recovery TimeRidership 

Correlation

4. Recovery Time 

Distributed to 

Passenger Benefit 

Assessment based on 

Criteria

Acela 2150 Washington-Boston √ √ √ Aligned to Customer OTP

Acela 2151 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2154 Washington-Boston √ √ √ Aligned to Customer OTP

Acela 2155 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2159 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2160 Washington-Boston √ √ Aligned to Customer OTP

Acela 2163 Boston-Washington √ √ √ Aligned to Customer OTP

Acela 2164 Washington-Boston √ √ √ Aligned to Customer OTP

Acela 2165 Boston-Washington √ √ √ Aligned to Customer OTP

Acela 2167 Boston-Washington √ √ √ Aligned to Customer OTP

Acela 2168 Washington-Boston √ √ Aligned to Customer OTP

Acela 2171 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2175 Boston-Washington √ √ √ Aligned to Customer OTP

Acela 2190 New York-Boston √ √ √ Aligned to Customer OTP

Acela 2253 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2254 Washington-Boston √ √ Aligned to Customer OTP

Acela 2255 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2256 Washington-Boston √ √ √ Aligned to Customer OTP

Acela 2258 Washington-Boston √ Aligned to Customer OTP

Acela 2259 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2260 Washington-Boston √ √ √ Aligned to Customer OTP

Acela 2261 Boston-Washington √ √ √ Aligned to Customer OTP

Acela 2275 Boston-Washington √ √ √ √ Aligned to Customer OTP

Acela 2290 New York-Boston √ √ √ Aligned to Customer OTP

Adirondack 68 New York-Montreal √ √ √ Aligned to Customer OTP

Adirondack 69 New York-Montreal √ √ √ Aligned to Customer OTP

Ethan Allen 

Express

290 New York-Rutland √ √ √ √ Aligned to Customer OTP

Ethan Allen 

Express

291 New York-Rutland √ √ Aligned to Customer OTP

Ethan Allen 

Express

292 New York-Rutland √ √ √ Aligned to Customer OTP
Page 3 of 6 

Ethan Allen 

Express

293 New York-Rutland√√√ Aligned to Customer OTP

Ethan Allen 

Express

295 New York-Rutland√ Aligned to Customer OTP

Ethan Allen 

Express

296 New York-Rutland√√√√ Aligned to Customer OTP

Maple Leaf 63 New York-Toronto√√ Aligned to Customer OTP

Maple Leaf 64 New York-Toronto√√√ Aligned to Customer OTP

New York -

Albany

230 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

232 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

233 New York-Albany√√√ Aligned to Customer OTP

New York -

Albany

234 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

235 New York-Albany√√√ Aligned to Customer OTP

New York -

Albany

236 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

237 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

238 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

241 New York-Albany√√√ Aligned to Customer OTP

New York -

Albany

242 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

243 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

244 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

245 New York-Albany√√√ Aligned to Customer OTP

New York -

Albany

250 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

252 New York-Albany√√√√ Aligned to Customer OTP
Page 4 of 6 

New York -

Albany

253 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

254 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

255 New York-Albany√√√ Aligned to Customer OTP

New York -

Albany

256 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

259 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

260 New York-Albany√√√√ Aligned to Customer OTP

New York -

Albany

261 New York-Albany√√√√ Aligned to Customer OTP

New York -

Niagara 

Falls

280 New York-Niagara 

Falls

√√√√ Aligned to Customer OTP

New York -

Niagara 

Falls

281 New York-Niagara 

Falls

√ Aligned to Customer OTP

New York -

Niagara 

Falls

283 New York-Niagara 

Falls

√ Aligned to Customer OTP

New York -

Niagara 

Falls

284 New York-Niagara 

Falls

√√√√ Aligned to Customer OTP

New York -

Niagara 

Falls

288 New York-Niagara 

Falls

√√√√ Aligned to Customer OTP

Northeast 

Regional

132 Washington-Boston√√ Aligned to Customer OTP

Northeast 

Regional

137 Boston-Washington√√√√ Aligned to Customer OTP

Northeast 

Regional

140 Washington-

Springfield

√√ Aligned to Customer OTP

Northeast 

Regional

141 Springfield-

Washington

√√√√ Aligned to Customer OTP
Page 5 of 6 

Northeast 

Regional

146 Washington-

Springfield

√√ Aligned to Customer OTP

Northeast 

Regional

148 Washington-

Springfield

√√ Aligned to Customer OTP

Northeast 

Regional

149 Boston-Washington√√√√ Aligned to Customer OTP

Northeast 

Regional

150 Washington-Boston√√√ Aligned to Customer OTP

Northeast 

Regional

163 Boston-Washington√√√√ Aligned to Customer OTP

Northeast 

Regional

167 Boston-Washington√√√√ Aligned to Customer OTP

Northeast 

Regional

168 Washington-Boston√√ Aligned to Customer OTP

Northeast 

Regional

177 Boston-Washington√√ Aligned to Customer OTP

Northeast 

Regional

178 Washington-Boston√√ Aligned to Customer OTP

Northeast 

Regional

179 Boston-New York√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

65 Boston-Newport 

News

√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

66 Newport News-

Boston

√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

67 Boston-Newport 

News

√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

82 Richmond-Boston√√√ Aligned to Customer OTP

Richmond / 

Newport 

86 Richmond-Boston√√√√ Aligned to Customer OTP
Page 6 of 6 

News / 

Norfolk

Richmond / 

Newport 

News / 

Norfolk

95 Boston-Norfolk√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

96 Newport News-

Boston

√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

174 Newport News-

Boston

√√√ Aligned to Customer OTP

Richmond / 

Newport 

News / 

Norfolk

194 Newport News-

Boston

√√√ Aligned to Customer OTP

Roanoke 171 Boston-Roanoke√√√√ Aligned to Customer OTP

Roanoke 176 Roanoke-Boston√√ Aligned to Customer OTP

Vermonter 54 Washington DC-St. 

Albans

√√√ Aligned to Customer OTP

Vermonter 55 Washington DC-St. 

Albans

√√√√ Aligned to Customer OTP

Vermonter 56 Washington DC-St. 

Albans

√√√ Aligned to Customer OTP

Vermonter 57 Washington DC-St. 

Albans

√√√√ Aligned to Customer OTP
Page 1 of 2

Exhibit B 

Metro-North Commuter Railroad Company’s (“Metro-North”) position on the disagreed-upon 

components of Amtrak’s train schedules. 

Metro-North, a New York State public benefit corporation and subsidiary of the Metropolitan 

Transportation Authority (“MTA”), operates the second-busiest commuter railroad in the country. PreCOVID, Metro-North operated 713 weekday revenue trains carrying an average of 289,000 weekday 

riders. Pursuant to certain Trackage Rights Agreements between Metro-North and Amtrak, Amtrak 

operates over Metro-North’s New Haven and Hudson Lines (Metro-North’s “territory”). Amtrak 

enters Metro-North’s New Haven Line territory in New Haven, CT and leaves the New Haven Line in 

New Rochelle, NY, continuing on to Penn Station in midtown Manhattan. Amtrak enters MetroNorth’s Hudson Line territory in Poughkeepsie, NY and exits near Riverdale in the Bronx, NY, again 

continuing on to Penn Station. 

The Metrics and Minimum Standards for Intercity Passenger Rail Service, 49 C.F.R. Part 273, 

published by the Federal Railroad Administration (“FRA”) on November 16, 2020 (the “Final Rule”) 

defines a “certified schedule” as a published train schedule for Amtrak trains that Amtrak and the host 

railroad jointly certify is aligned with the Customer On-Time Performance (“OTP”) metric and 

standard set forth in the Final Rule. To ensure Amtrak’s train schedules meet the Customer OTP metric 

and standard, Amtrak’s schedules must provide trains with sufficient running time while in MetroNorth’s territory. Amtrak’s trains traverse long distances; Metro-North has no control over events 

outside of its territory and must account for such unknowns in its review and certification of Amtrak’s 

schedules. As such, the “host running time” metric, also established by the Final Rule, which compares 

a train’s actual running time with the scheduled running time between the first and final reporting 

points for a host railroad, is important and must be accurately calculated prior to certification to 

demonstrate the schedule adjustments necessary for Amtrak trains to have enough time to traverse 

Metro-North’s territory and successfully meet the Customer OTP metric and standard. 

Amtrak has submitted 24 train schedules (26% of the uncertified schedules) to be certified for trains 

that are not currently operating and have no proposed effective date to begin operating. It is MetroNorth’s position, which is supported by the regulation, that trains with no defined plan to operate need 

not be certified at this time. Metro-North is fully committed to work with Amtrak on certifying these 

schedules once they have a proposed effective date. There are numerous factors that impact the run 

time of a train including, but not limited to, time of day, track work, infrastructure work, etc. Without 

knowing when a train will operate, it is neither feasible nor realistic to determine whether the schedule 

is possible. For example, on Metro-North’s New Haven Line, the State of Connecticut will be 

replacing Walk Bridge in Norwalk, Connecticut. This major infrastructure project has the potential to 

reduce the number of available tracks on which to operate from 4 to 2 for several years. This example 

is only one that demonstrates why it is necessary for Amtrak to identify the intended date of operation 

for Metro-North to appropriately certify a schedule. Without this critical factual information, it is pure 

conjecture as to whether the schedule meets the Customer and OTP metric and standard. Furthermore, 

the regulation does not require future schedules without proposed effective dates to be certified, so it 

is unclear why Amtrak included these schedules from the outset. 

Metro-North is committed to continuing to work with Amtrak in an effort to certify the remaining 

schedules and to ensure the schedules meet the Customer OTP metric and regulatory requirement. As 

an illustration of this commitment, Amtrak recently returned 17 trains to service and Metro-North is 

agreeable to certifying 8 of those schedules that align with the Customer OTP metric and standard. 

Those trains are: 293, 239, 149, 163, 82, 132, 54 and 2169. 
Page 2 of 2

Additionally, Metro-North and Amtrak recently implemented a schedule change on Metro-North’s 

Hudson Line due to the infrastructure effects of Tropical Storm Ida. Metro-North is willing to certify 

all 26 Amtrak trains currently operating on the Hudson Line under the revised schedule. However, 

Amtrak has not provided a response to Metro-North as to whether Amtrak is agreeable to certify those 

schedules. The 26 schedules on the Hudson Line represent approximately 28% of the remaining 

uncertified schedules. 

The attached Table 1 lists each Amtrak train that Metro-North has not certified to date based on the 

well-established framework and analysis that Metro-North has used since the regulation became 

effective. 

There are currently 92 schedules that are uncertified according to Amtrak’s list. If this amount is 

reduced by the 24 schedules not currently in operation, the 26 schedules on the Hudson Line, and 8 

schedules that Metro-North is agreeable to certify, there are only 34 remaining schedules to certify. 

Of those, current operational data shows that these trains do not consistently meet Customer OTP in 

accordance with the current schedule and are frequently late. Metro-North cannot certify Amtrak 

schedules for which data reveals an incapability to traverse Metro-North territory in the run time 

printed on the schedule. Metro-North trusts that the spirit of the regulation requires these trains to be 

adjusted to reflect actual run time proven through operational data. 

Although Amtrak claimed in their narrative that “MNRR remains the only host railroad for which 

Amtrak has uncertified schedules,” we believe this characterization is not fully accurate. Many other 

railroads immediately classified schedules as “disputed” in May 2021, and they currently remain in a 

disputed status with Amtrak’s schedules. In contrast, Metro-North has attempted in good faith to 

continue reviewing and discussing the schedules with Amtrak in furtherance of meeting the Customer 

OTP standards over the last several months. As demonstrated by the information above, Amtrak has 

declined to compromise with Metro-North on these issues to make effective progress in certification. 

As another passenger railroad who aims to provide the best service possible to our customers and those 

for Amtrak, we have attempted to resolve our schedule discrepancies and believed that strategy to be 

more beneficial to the rail network than prolonging disagreement and simply classifying schedules as 

“disputed” like so many other railroads did at the commencement of this process. We also believe that 

the spirit of the regulation calls for railroads to engage in both meaningful and reasonable negotiations 

on the schedules; but if we are not met with that same belief, we will similarly review our options to 

resolve these issues pursuant to the regulation. 

Metro-North remains dedicated to meeting the intent of 49 CFR Part 273 and will maintain our 

obligations to support the improved metrics and minimum standards for measuring the performance 

and service quality of intercity passenger train operations. 

Very truly yours, 

Catherine Rinaldi 

President 

Metro-North Commuter Railroad Company 
Train

(1) Train is Currently 

Operating as of May 

2021

(2) Schedule Provided to 

Metro-North between 

May 2020 and May 2021

(3) Metro-North Action 

Taken

(4) MNR-Calculated 

Running Time (Minutes)

(5) Current Amtrak 

Running Time (Minutes)

(6) Running Time 

Deficiency

293 No No Certification Approved 75 76 0

239 No No Certification Approved 75 75 0

290 Yes Yes Review for Certification 75 70 5

291 Yes Yes Review for Certification 75 70 5

292 Yes Yes Review for Certification 75 70 5

295 No No Review for Certification 75 70 5

296 No No Review for Certification 75 70 5

63 Yes Yes Review for Certification 75 70 5

64 Yes Yes Review for Certification 75 71 4

233 Yes Yes Review for Certification 75 70 5

236 Yes Yes Review for Certification 75 70 5

238 Yes Yes Review for Certification 75 70 5

241 Yes Yes Review for Certification 75 70 5

243 Yes Yes Review for Certification 75 70 5

250 Yes Yes Review for Certification 75 70 5

253 Yes Yes Review for Certification 75 70 5

255 No No Review for Certification 75 70 5

256 No No Review for Certification 75 70 5

259 Yes Yes Review for Certification 75 70 5

260 Yes Yes Review for Certification 75 70 5

283 Yes Yes Review for Certification 75 70 5

284 Yes Yes Review for Certification 75 70 5

232 Yes Yes Review for Certification 73 70 3

234 Yes Yes Review for Certification 73 68 5

237 Yes Yes Review for Certification 73 67 6

244 Yes Yes Review for Certification 73 68 5

280 Yes Yes Review for Certification 73 68 5

281 Yes Yes Review for Certification 73 68 5

68 No No Waiting for Schedule

69 No No Waiting for Schedule
Train

(1) Train is Currently 

Operating as of May 

2021

(2) Schedule Provided to 

Metro-North between 

May 2020 and May 2021

(3) Metro-North Action 

Taken

(4) MNR-Calculated 

Running Time (Minutes)

(5) Current Amtrak 

Running Time (Minutes)

(6) Running Time 

Deficiency

230 No No Waiting for Schedule

235 No No Waiting for Schedule

242 No No Waiting for Schedule

245 No No Waiting for Schedule

252 No No Waiting for Schedule

254 No No Waiting for Schedule

261 No No Waiting for Schedule

288 No No Waiting for Schedule

149 No Yes Certification Approved 79 82 0

163 No Yes Certification Approved 79 80 0

82 No Yes Certification Approved 79 84 0

132 No No Certification Approved 77 79 0

54 No Yes Certification Approved 77 77 0

2169 No No Certification Approved 73 73 0

137 Yes Yes Review for Certification 79 71 8

140 Yes Yes Review for Certification 79 75 4

141 Yes Yes Review for Certification 79 75 4

148 Yes Yes Review for Certification 79 76 3

150 Yes Yes Review for Certification 79 74 5

167 Yes Yes Review for Certification 79 74 5

168 Yes Yes Review for Certification 79 76 3

177 Yes Yes Review for Certification 79 75 4

178 Yes Yes Review for Certification 79 76 3

179 No Yes Review for Certification 79 77 2

65 Yes Yes Review for Certification 79 72 7

66 Yes Yes Review for Certification 79 76 3

67 Yes Yes Review for Certification 79 72 7

96 Yes Yes Review for Certification 79 74 5

174 Yes Yes Review for Certification 79 76 3

194 Yes Yes Review for Certification 79 76 3

176 Yes Yes Review for Certification 79 76 3

146 Yes Yes Review for Certification 77 73 4

171 Yes Yes Review for Certification 77 74 3

55 No Yes Review for Certification 77 72 5

2154 Yes Yes Review for Certification 75 68 7

2253 Yes Yes Review for Certification 75 72 3
Train

(1) Train is Currently 

Operating as of May 

2021

(2) Schedule Provided to 

Metro-North between 

May 2020 and May 2021

(3) Metro-North Action 

Taken

(4) MNR-Calculated 

Running Time (Minutes)

(5) Current Amtrak 

Running Time (Minutes)

(6) Running Time 

Deficiency

2259 Yes Yes Review for Certification 75 71 4

86 No No Review for Certification 75 70 5

95 Yes Yes Review for Certification 75 70 5

56 No Yes Review for Certification 75 73 2

57 No Yes Review for Certification 75 74 1

2150 Yes Yes Review for Certification 73 70 3

2155 Yes Yes Review for Certification 73 68 5

2159 Yes Yes Review for Certification 73 69 4

2163 Yes Yes Review for Certification 73 70 3

2254 Yes Yes Review for Certification 73 70 3

2255 Yes Yes Review for Certification 73 70 3

2256 Yes Yes Review for Certification 73 67 6

2151 No No Waiting for Schedule

2160 No No Waiting for Schedule

2164 No No Waiting for Schedule

2165 No No Waiting for Schedule

2167 No Yes Waiting for Schedule

2168 No Yes Waiting for Schedule

2171 No No Waiting for Schedule

2175 No No Waiting for Schedule

2190 No No Waiting for Schedule

2258 No No Waiting for Schedule

2260 No No Waiting for Schedule

2261 No Yes Waiting for Schedule

2275 No No Waiting for Schedule

2290 No No Waiting for Schedule